Baral v. United States
In Baral v. United States, 120 S. Ct. 1006, 1009 (2000), the Supreme Court held that under 26 U.S.C. section 6513(b)(1) of the Internal Revenue Code, remittances of estimated income tax were "paid" on the due date for the taxpayer's income tax return.
The Court made clear in Baral that it was not overruling Rosenman, and that its decision was based on its interpretation of section 6513, which provides that "any amount paid as estimated income tax for any taxable year shall be deemed to have been paid on the last day prescribed for filing the return." 26 U.S.C. 6513(b)(1); Baral, 120 S. Ct. at 1009-1011.